On July 4, 2025, President Trump signed the “One Big Beautiful Bill Act” (OBBB), H.R. 1, into law. The OBBB extended and made permanent the general qualified opportunity fund (QOF) legislative framework for investments in...more
7/21/2025
/ Capital Gains ,
Economic Development ,
Federal Budget ,
Federal Funding ,
Investment ,
New Legislation ,
One Big Beautiful Bill Act ,
Opportunity Zones ,
Qualified Opportunity Funds ,
Real Estate Investments ,
Rural Areas ,
Rural Development ,
Tax Cuts and Jobs Act ,
Tax Incentives ,
Tax Legislation ,
Tax Reform ,
Trump Administration
On July 4, 2025, President Donald Trump signed H.R. 1 into law, the budget reconciliation bill known as the One Big Beautiful Bill Act (the Act). As discussed in our prior alert released following the passage by the House of...more
7/18/2025
/ Bonus Depreciation ,
Business Losses ,
Internal Revenue Code (IRC) ,
Investors ,
IRS ,
New Legislation ,
One Big Beautiful Bill Act ,
Opportunity Zones ,
Qualified Business Income ,
Real Estate Investments ,
REIT ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Exemptions ,
Tax Planning ,
Tax Reform ,
Trump Administration
On July 4, 2025, President Donald Trump signed H.R. 1 into law, the budget reconciliation bill known as the One Big Beautiful Bill Act (the Act). As discussed in our prior alert following the passage by the House of...more
7/16/2025
/ Capital Gains ,
Internal Revenue Code (IRC) ,
Investment ,
Investment Funds ,
IRS ,
Itemized Deductions ,
One Big Beautiful Bill Act ,
Private Equity Funds ,
Qualified Small Business Stock ,
Tax Deductions ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Trump Administration
FUNDamentals is a periodic digest of news and information specifically for private funds and their managers. In this issue, we highlight some fundraising trends, new marketing rule FAQs, fund liquidity trends (limited...more
6/17/2025
/ Federal Budget ,
Financial Markets ,
Financial Services Industry ,
Fund Managers ,
Investment ,
Investment Funds ,
Investment Management ,
Limited Partnerships ,
Liquidity ,
Private Equity ,
Private Equity Funds ,
Proposed Legislation ,
Regulatory Reform ,
Regulatory Requirements ,
Trump Administration
On May 22, 2025, the House of Representatives passed H.R. 1, the budget reconciliation bill known as the One Big Beautiful Bill Act (the Tax Bill). The Tax Bill proposes amendments to the Internal Revenue Code (the Code) that...more
6/5/2025
/ Federal Budget ,
Internal Revenue Code (IRC) ,
Investment Funds ,
IRS ,
Proposed Amendments ,
Proposed Legislation ,
Real Estate Development ,
Real Estate Investments ,
REIT ,
Tax Credits ,
Tax Deductions ,
Tax Reform ,
Trump Administration
On May 22, 2025, the House of Representatives passed H.R. 1, the budget reconciliation bill known as the One Big Beautiful Bill Act (the Tax Bill). The Tax Bill proposes amendments to the Internal Revenue Code (the Code) that...more
6/5/2025
/ Federal Budget ,
Fund Managers ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment Funds ,
Investment Management ,
IRS ,
New Legislation ,
Private Equity ,
Proposed Legislation ,
Tax Planning ,
Tax Reform ,
Trump Administration
Summary -
On November 28, the Tax Court, granting the Internal Revenue Service (IRS) summary judgment, held in Soroban Capital Partners LP v. Commissioner that a state law limited partner who is limited in name only, is...more
On May 3, the Securities and Exchange Commission (SEC) adopted final amendments that call for certain quantitative and qualitative disclosure requirements with respect to repurchases of an issuer’s equity securities that are...more
On May 19, 2023 the Internal Revenue Service (IRS) released AM 2023-003 (the Memo or GLAM) holding that the Foreign Investment in Real Property Tax Act’s (FIRPTA’s) 5% publicly traded exception (the 5% exception) applies at...more
Overview -
This article highlights comment letters publicly issued by the Securities and Exchange Commission (SEC) to Real Estate Investment Trusts (REITs) during 2022. The SEC issues comment letters in connection with...more
Introduction -
Gain of a fund or other investment partnership from a capital asset sale held for over one year is taxed to the fund’s partners at favorable long-term capital gains rates. Until 2018, this general rule...more
Introduction and Background -
Treasury and the IRS issued proposed regulations on July 31, 2020 under Section 1061 of the Code (Proposed Regulations). Section 1061 effectively creates a three-year holding period...more
8/17/2020
/ Capital Gains ,
Carried Interest ,
Economic Substance Doctrine ,
Holding Periods ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
Proposed Regulation ,
Real Estate Investments ,
REIT ,
Reporting Requirements ,
RICs ,
S-Corporation ,
Tax Cuts and Jobs Act ,
U.S. Treasury
The recently enacted Coronavirus Aid, Relief, and Economic Security Act (CARES Act), as well as IRS guidance released in the last few days, aim to provide real estate businesses, among others, with decreases or delays in...more
In Notice 2020-23, released on April 9, the Department of the Treasury expanded the relief offered in earlier notices to apply to a broader set of taxpayers, additional tax returns and tax payments required to be filed or...more